State v. Malloy
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The Supreme Court in this criminal case repudiated the sweeping language of its opinion in State v. James, 13 P.3d 576 (Utah 2000), and held that it can no longer be said that it makes no constitutional difference, as regards community caretaking concerns, whether a police officer opens a car door or asks a driver to do so.
Defendant was charged with felony DUI and possession of drugs and drug paraphernalia. Defendant moved to suppress the evidence discovered after an officer looked inside his pickup truck, which was parked in a store parking lot, opened the truck door, and saw evidence of drug paraphernalia between Defendant's feet. The district court denied the motion. The court of appeals affirmed on alternative grounds, holding that the officer was justified in opening the car door incident to a lawful traffic stop under the standard in James. The Supreme Court affirmed, holding (1) the identity of the door-opener may well affect the reasonableness of a given police encounter; and (2) the denial of Defendant's motion to suppress was proper under the authority of Davis v. United States, 564 U.S. 229 (2011).
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